State v. Banks

Citations

• 2021 Ohio 4330

Syllabus

CONFRONTATION—HARMLESS ERROR—R.C. 959.131(B)—EVIDENCE—SUFFICIENCY: Any violation of defendant's right to confrontation of a witness who testified through zoom technology was harmless error where the remaining evidence, absent the testimony in question, was sufficient to support the convictions. [See CONCURRENCE: While any violation of defendant's right to confront witnesses would constitute harmless error in this case, Ohio courts should reassess the scope of Ohio's Confrontation Clause in light of textual and historical differences between Ohio's Confrontation Clause and the federal Confrontation Clause.] Defendant's convictions for cruelty against a companion animal were supported by sufficient evidence and not against the manifest weight of the evidence where the evidence established that he hit the dogs multiple times and threw a crate at the dogs.